Los Angeles Cent. Animal Hospital, Inc. v. Commissioner
United States Tax Court
Petitioner acquired the assets of a veterinary hospital, including certain medical record files containing the names and addresses of the pet owners and the medical histories of each animal patient over the last 2 years. Petitioner claimed depreciation deductions for the files based on the allocation of the purchase price in the agreement of sale. Held: The medical information is intangible property with a useful life of 7 years.
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Petitioner acquired the assets of a veterinary hospital, including certain medical record files containing the names and addresses of the pet owners and the medical histories of each animal patient over the last 2 years. Petitioner claimed depreciation deductions for the files based on the allocation of the purchase price in the agreement of sale. Held: The medical information is intangible property with a useful life of 7 years. Its value is separable from the goodwill and going-concern value of the acquired business. Held, further, the amount of the purchase price allocable to the files…
1Opinion of the Court
Quealy, Judge:
Respondent determined deficiencies in petitioner’s Federal income tax in the amounts of $4,636.56 and $4,812.52 for the taxable years ending on May 31, 1971, and May 31, 1972.
The only issue for decision is whether petitioner is entitled to a deduction for the amortization of the cost of medical record cards acquired in the purchase of an animal hospital.
FINDINGS OF FACT
Some of the facts have been stipulated. The stipulation of facts and the exhibits attached thereto are incorporated herein by this reference.
Petitioner Los Angeles Central Animal Hospital, Inc., is a corporation…
2Cases cited8 opinions
- Richard M. Boe and Mary Lots Boe v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1962
- Houston Chronicle Publishing Company, Plaintiff-Appellee-Cross v. United States of America, Defendant-Appellant-CrossCourt of Appeals for the Fifth Circuit · 1973
- Commissioner of Internal Revenue v. Seaboard Finance Company, Seaboard Finance Company, Cross v. Commissioner of Internal Revenue, CrossCourt of Appeals for the Ninth Circuit · 1966
- Manhattan Co. of Virginia, Inc. v. CommissionerUnited States Tax Court · 1968
- Commissioner of Internal Revenue v. Maurice L. KillianCourt of Appeals for the Fifth Circuit · 1963
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